LFPIORPI, Article 17, section IX

AML compliance for armoring companies in Mexico

If you regularly or professionally armor land vehicles or buildings, you must identify the client from 2,410 UMA and file a notice with the UIF from 4,815 UMA. SiennaDocs keeps the file, the threshold and the notice for every job.

Who is covered?

Article 17, section IX of the LFPIORPI treats as a vulnerable activity the regular or professional armoring of land vehicles, new or used, and of buildings, for 2,410 times the daily UMA or more.

IX. La prestación habitual o profesional de servicios de blindaje de vehículos terrestres, nuevos o usados, así como de bienes inmuebles, por una cantidad igual o superior al equivalente a dos mil cuatrocientas diez veces el valor diario de la UMA.

Serán objeto de Aviso ante la Secretaría las actividades anteriores, cuando el monto del acto u operación sea igual o superior al equivalente a cuatro mil ochocientas quince veces el valor diario de la UMA;

LFPIORPI, Article 17, section IX. Official Spanish text in force; latest amendment to the Act: DOF, July 16, 2025.

Key points

It covers the armoring service; selling already armored vehicles on a regular or professional basis is section VIII (vehicles).
It applies to land vehicles, new or used, and to buildings.
Customs clearance of ballistic-resistant materials for vehicle armoring always requires a notice (section XIV), filed by the customs broker, attorney or agency, or by whoever clears the goods without one.
The notice is due no later than the 17th of the month after the month in which the transaction took place (Art. 23 of the Act). From November 30, 2026, the transaction date for the notice is the date on which payment for the service is deemed settled and the notice threshold has been reached (General Rules, Art. 24 Bis, section V, as amended by Agreement 115/2026).
If several services for the same client, each of 2,410 UMA or more, reach or exceed 4,815 UMA within a period of up to six months, a notice is filed; the notice relates to the service that reaches or exceeds the threshold, even if the six months have not elapsed (Art. 7 of the Regulations).

Typical businesses

Automotive armoring companies
Architectural armoring companies
Ballistic system installers for land vehicles or buildings

Identification and notice thresholds

In multiples of the daily UMA. Peso amounts use the 2026 UMA of MX$117.31.

Case	Identification	Notice to the UIF
Armoring of land vehicles or buildings	≥ 2,410 UMA (≈ MX$282,717.10)	≥ 4,815 UMA (≈ MX$564,847.65)

Cash limit · Art. 32, section V: Armoring services for vehicles or buildings. Paying or accepting payment in bills and coins (pesos or foreign currency) or in precious metals is prohibited when the transaction is worth 3,210 UMA or more (≈ MX$376,565.10) on the day payment is made or the obligation is met, including taxes and other charges, in one or several installments and even when that cash payment is made through a financial institution. The prohibition also applies when a set of transactions is paid and a single person provides the funds to pay them (Art. 32 of the Act; Arts. 6 and 42 of the Regulations). Consigning that payment in cash or precious metals is also prohibited (Art. 32, section VIII).

Source: LFPIORPI (current text, amended in the DOF on July 16, 2025), its Regulations (amended in the DOF on March 27, 2026) and the General Rules. See the full list of vulnerable activities for 2026

Your obligations as an obligated party

Identify the client: Identify and know the client directly, verify their identity with documents or other officially recognized means of identification, and obtain a copy of them. (Art. 18, sec. I)
Business or occupation: Ask for it whenever there is a business relationship. (Art. 18, sec. II)
Beneficial owner: If the client is a legal entity, trust or other legal arrangement, obtain documents or other officially recognized means of identification that identify its beneficial owner. If the client is an individual, obtain their statement on whether or not they know that a beneficial owner exists and, where applicable, the documentation to identify them. (Art. 18, sec. III)
Keep records 10 years: Keep the information on every transaction and the client's identification for at least ten years from the transaction date. (Art. 18, sec. IV)
Registry enrollment: Register in the Registry of Persons Carrying Out Vulnerable Activities through the online portal, and update or cancel your registration when applicable. (Art. 18, sec. IV Bis)
Notices to the UIF: Filed through the SAT portal by the 17th of the following month. If there is suspicion, within 24 hours of it arising or of learning the information on which it is based, even if the transaction did not take place. (Arts. 18, sec. VI and 23)
Nil report: If there were no reportable transactions in the month, you file a report saying so. (General Rules, Art. 25)
Risk-based approach: Assess your own risks and those of your clients. The assessment must be available from March 1, 2027. (Art. 18, sec. VII)
Internal policy manual: Criteria and procedures, including monitoring of politically exposed persons. Today, the General Rules require a policy document 90 days after registration (Art. 37); the manual with the risk methodology, from March 1, 2027. (Art. 18, sec. VIII)
Annual training: Annual training programs for the board or sole administrator, management, the compliance officer and staff who deal directly with clients, plus staff selection processes. First annual training period: 2027. (Art. 18, sec. IX)
Automated monitoring: Detect out-of-profile transactions, aggregate totals over up to six months where applicable and apply enhanced monitoring to politically exposed or high-risk clients. Today, tracking and aggregation (Regulations, Art. 7; General Rules, Art. 19); automated mechanisms by June 1, 2027. (Art. 18, sec. X)
Annual audit: Internal or independent external review; external if your risk is high. First audited year: 2028. (Art. 18, sec. XI)
Compliance representative: Legal entities and those acting through trusts or any other legal arrangement appoint one before the Ministry of Finance and keep the appointment current. Individuals comply personally and directly, unless they file their notices through a collegiate entity (entidad colegiada). (Art. 20)

How SiennaDocs helps

KYC files: One file per client with documents, expiry dates, approvals and audit log.
Document reading: Extracts data from IDs and documents so you don't type it by hand.
Watchlists: Screening against OFAC, the UN, the SAT 69-B and 69-B Bis lists and countries on the FATF lists.
Beneficial owner: Record of who controls each legal entity or trust.
Client risk: Risk-based assessment with a traffic-light score per client.
Thresholds and aggregation: Flags when a transaction, or a six-month total, reaches the threshold.
XML notices: Generates the notice in the official format, ready to file with the UIF through the SAT portal.
Alerts and audit trail: Alerts on expiries and incidents, and traceability of every action.

Frequently asked questions

From what amount must I identify the client?

From 2,410 UMA (about MX$282,717.10 in 2026) per armoring service.

Can I accept cash for armoring?

Not from 3,210 UMA: Article 32, section V prohibits paying for those services or accepting payment for them in bills and coins, in pesos or foreign currency, or in precious metals, even through a financial institution. Consigning that payment in cash or precious metals is also prohibited (section VIII).

What if I sell already armored cars?

If done on a regular or professional basis, that sale is a vehicle sale (section VIII), with its own thresholds: identification from 3,210 UMA and notice from 6,420 UMA.

Other vulnerable activities

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